The IRS considers income received the moment that you are able to collect it without restrictions. This is not a capital gain situation as the agreement with the charity does not involve any security instruments. To be taxable, the income does not need to be deposited into your account, it simply needs to be made available to you without restriction. Based on the information in the story, that appears to be the case. If the information is true, Mr. Moore had constructive receipt and should be taxed on the income.